In re Shriram Paper Industries (GST AAR Haryana)
The Haryana Authority for Advance Ruling considered the application of M/s Shriram Paper Industries concerning classification and GST rate of boards manufactured entirely from agricultural crop residues such as bagasse, paddy straw, wheat straw and mustard straw. The applicant stated that no wood, resin, synthetic adhesive or chemical binder is used. The manufacturing process involves cleaning, cooking or steaming, mechanical refining into fibres, sheet formation, drying, calendaring, cutting and hot pressing, with bonding through the natural properties of the fibres. The finished products are marketed as “Straw Board”, “Agro Board” or “Eco. Board” and supplied for bookbinding, file boards, stationery, packaging support layers and furniture backing applications. The application was found maintainable under Section 97(2) of the CGST/HGST Acts, as the questions concerned classification of goods under Section 97(2)(a) and applicability of a notification under Section 97(2)(b). The applicant had also declared that the issue was neither pending nor decided in its own case, and the application was admitted on merits.
The Authority identified the principal issues as whether the goods constitute particle board or fibre board, their appropriate classification under the Customs Tariff Act, 1975, applicability of Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025, interpretation of the expression “HSN 44 or any chapter”, and the persuasive value of earlier rulings concerning similar products. Heading 4411 covers “Fibre board of wood or other ligneous materials, whether or not bonded with resins or other organic substances.” The Authority considered the relevant HSN Explanatory Notes, which state that fibreboard may be manufactured from wood chips or other defibred ligneo-cellulosic material, including bagasse, and that fibres may be bonded through their natural felting properties or with additives. The Authority therefore noted that resin is not an essential ingredient for fibreboard.
The Authority distinguished Heading 4410 concerning particle board from Heading 4411 concerning fibreboard based on the nature of the material and manufacturing process. The record showed that the agricultural residues were digested and passed through disc refiners to convert them into fibres, which were then formed into sheets, pressed and dried. As no resin or synthetic adhesive was used, the Authority found that the product derived its essential character from fibres obtained from ligno-cellulosic agricultural residues rather than particles or chips agglomerated with an added binder. It accordingly held that the goods were appropriately classifiable under Heading 4411 of the First Schedule to the Customs Tariff Act, 1975.
The next question was whether the goods were covered by Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate), which reads: “Particle board or fibre board manufactured from agricultural crop residues – HSN 44 or any chapter.” The Authority identified three conditions: the goods must be particle board or fibre board; they must be manufactured from agricultural crop residues; and they must be covered by “HSN 44 or any chapter.” It found the first two conditions satisfied because the goods were fibreboards manufactured from agricultural crop residues.
On the expression “HSN 44 or any chapter”, the Authority held that its wording indicated that the benefit was not confined exclusively to Chapter 44. It observed that, had the intention been to restrict the benefit to Chapter 44, the words “or any chapter” would have been unnecessary. The Authority therefore concluded that the description of the goods, rather than restriction to a particular tariff chapter, governs eligibility under the entry. In the present case, the goods were independently found classifiable under Heading 4411 of Chapter 44.
The Authority consequently ruled that the applicant’s boards are fibre boards, that they are covered by Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate), and that the applicable GST rate is 5%. The fourth query concerning an alternative HSN classification and rate was treated as not applicable.
Applicant Represented by Sh. Paras Gilhotra, Advocate
FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, HARYANA
APPLICANT’S ELIGIBILITY FOR SEEKING AN ADVANCE RULING:
To file an application before the Authority of Advance Ruling, the applicant must satisfy the conditions prescribed under the Central Goods and Services Tax Act, 2017 (hereinafter referred to as CGST Act 2017) and Haryana Goods and Services Tax Act, 2017 (hereinafter referred to as HGST Act, 2017). Since the provisions of both the Acts are pari materia, any reference to provisions of CGST Act, 2017 in this order should be construed as a reference to corresponding provisions in HGST Act, 2017 as well. Section 97(2) of the CGST Act, 2017 prescribes that an Advance Ruling may be sought inter alia on the questions of (a) classification of any goods or services or both (b) applicability of a notification issued under the provisions of this Act. Further, proviso with reference to the Section 98(2) of CGST Act, 2017 states that where the questions raised in the application is already pending or decided in any proceedings in the case of the applicant under any provision of this Act, the application may be rejected by the Advance Ruling Authority after providing an opportunity of being heard to the applicant. And in this case the applicant has undertaken in form ARA-01 that the issue is neither pending nor decided in any proceedings under any of the provisions of the Act. Besides the applicable fees in the case has also been paid. So, it is eligible to seek an Advance Ruling under the above provisions and the case has been considered on merits.
Statement of Facts as per ARA-01:
The applicant, M/s Shriram Paper Industries is engaged in manufacturing of eco-friendly boards entirely made from agricultural crop residues such as bagasse, paddy straw, and wheat straw, without using any resin, synthetic adhesive, or chemical binder.
The process involves cleaning and preparing the residues, cooking/steaming in digestors, refining in disc refiners, forming pulp into sheets, and pressing under heat and pressure to achieve bonding through natural lignin activation. The boards are then dried, cut, and supplied in standard sheet sizes and thicknesses.
The finished product is dense, uniform, and brownish, suitable for bookbinding, file boards, stationery, and furniture applications.
The applicant seeks an Advance Ruling on the classification (HSN) and applicable GST rate for these boards under Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025, specifically Entry No. 292, sub-entry (h):
“Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter.”
The phrase “HSN 44 or any chapter” is of decisive importance and demonstrates that concessional treatment is intended to apply broadly to all particle or fibre boards manufactured from agricultural crop residues, regardless of the tariff heading.
The applicant’s manufactured goods i.e. board meet this criterion fully, being 100% derived from crop residues and possessing the characteristics of fibre boards.
1. The applicant is engaged in the manufacture of boards made entirely from agricultural crop residues such as bagasse, paddy straw, and wheat straw.
2. The raw materials used are exclusively agricultural residues obtained from sugar mills and local farmers. No wood, sawdust, MDF dust, or synthetic material is used. No resin, glue, or chemical binder is employed; the fibres bond naturally through lignin activation.
3. The manufacturing process involves cleaning and preparation of residues, cooking/steaming in digestors, refining in disc refiners, sheet formation, drying, and hot pressing under heat and pressure to form compact boards.
4. The finished boards are brownish, dense, and uniform, available in various thicknesses. They are used for book-binding, file boards, stationery, and furniture-backing applications.
5. The process is entirely mechanical and thermal, with no use of hazardous chemicals or resins. The product is marketed as “Straw Board,” “Bagasse Board,” or “Eco Board,” and invoices describe it as board manufactured from agricultural crop residues.
6. The applicant seeks an advance ruling to confirm the classification and applicable GST rate under Entry No. 292(h) of Notification No. 9/2025-Central Tax (Rate), dated 17th September 2025, which covers “Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter.”
7. No proceedings on this issue are pending or have been decided under the GST law in the applicant’s case.
Applicant’s Interpretation of Law and Facts:
1. Legal Framework:
The issue relates to the classification and applicable rate of GST on boards manufactured from agricultural crop residues. Entry No. 292 of Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025 prescribes a concessional rate of 5 percent for certain goods manufactured from agricultural residues.
Sub-entry (h) thereof specifically reads:
“Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter.”
2. Interpretation of the Expression “HSN 44 or any chapter”:
The phrase “or any chapter” signifies a deliberate legislative intent to make the entry material-based rather than tariff-based.
The decisive factor for coverage is the use of agricultural crop residues as raw material, not the precise HSN classification of the finished product.
Therefore, any board made predominantly or wholly from such residues qualifies for the concessional rate, even if it might otherwise be classifiable outside Chapter 44.
3. Applicability to the Applicant’s Product:
(a) The applicant’s boards are produced entirely from bagasse, paddy straw, and wheat straw, all of which are agricultural crop residues.
(b) The process is purely mechanical and thermal, relying on heat and pressure to achieve natural fibre bonding through lignin activation, without the use of resins or chemical binders.
(c) The resulting product is a fibre-based sheet material, commercially known as Straw Board, Bagasse Board, or Eco Board, having the structural and functional properties of fibre board. These characteristics fit squarely within the description of “particle board or fibre board manufactured from agricultural crop residues.”
4. Inclusion of Bagasse Board within the Same Entry:
The same notification already includes “Bagasse Board” under sub-entry (f) of Entry 292, taxable at 5 percent.
When the legislature has extended concessional treatment to Bagasse Board, it logically follows that other boards manufactured from similar agricultural residues, or from combinations including bagasse, are also intended to be covered.
Excluding such comparable agro-residue boards would defeat the evident intent of the notification, which is to provide uniform treatment for all residue-based board products. The applicant’s product, being a combination of bagasse, paddy straw, and wheat straw, is therefore squarely within the intended scope of Entry 292(h).
5. Purpose and Legislative Intent:
The object of Entry 292 is to encourage utilization of agricultural waste and discourage stubble
burning, thereby supporting environmental sustainability.
Granting the concessional 5 percent rate to the applicant’s product aligns fully with this policy and ensures consistency of tax treatment across all residue-based boards.
7. Accordingly, the applicant’s product satisfies every requirement of Entry 292(h)
(a) The correct classification is “Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter.”
(b) The applicable rate of GST is 5 percent (2.5 percent CGST + 2.5 percent SGST).
(c) If, however, the Authority holds otherwise, the applicant seeks a clear determination as to the appropriate HSN heading and rate of GST applicable.
QUERIES
1. Whether the boards manufactured by the applicant from agricultural crop residues such as bagasse, paddy straw, and wheat straw, using heat and pressure without any resin, synthetic adhesive, or chemical binder, are classifiable as particle boards or fibre boards for the purposes of GST.
2. Whether such boards are covered under Entry No. 292, sub-entry (h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025, which reads: “Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter.”
3. Whether the phrase “HSN 44 or any chapter” should be interpreted to grant the concessional GST rate of 5 percent to all particle or fibre boards made from agricultural crop residues, irrespective of their specific tariff heading, the decisive criterion being that they are wholly derived from agricultural crop residues and possess the essential character of fibre boards.
4. If, however, the product is not considered to fall within Entry 292 (h) of the above notification, under what HSN heading would the said boards appropriately fall, and what rate of GST would be applicable to them under the prevailing tariff and rate structure.
PERSONAL HEARING AND DISCUSSION:
The matter has been presented by Sh. Paras Gilhotra, Advocate on 20.05.2026 behalf of the applicant before the authority. All the aspects of the case discussed in detail during the personal hearing. In this matter, it is observed that the applicant is engaged in the manufacturing of the boards made entirely from agricultural crop residues. And the raw material is purchased from sugar mills and local farmers. The complete manufacturing process has been explained by the applicant during the personal hearing to the Authority. The product is marketed as Straw board, begasse board or echo board. The applicant has sought the ruling to confirm the classification of the said goods as well as the rate of tax.
We have gone through the facts of the case, documents on the case record file and submissions made by the applicant. Considering all the factual and legal aspects and the notification no.9/2025 CT Rate dated 17.09.2025, it can be said that agro residue-based board are covered under Chapter 44 and the Ruling in the matter as following:
FINDINGS AND DISCUSSION
1.1 We have gone through the facts of the case, documents available on record, submissions made by the applicant in Form GST ARA-01, the statement of facts, the written submissions, the documents placed on record , report 03.06.2026 from jurisdictional authority and the oral submissions made by Sh. Paras Gilhotra, Advocate, during the course of personal hearing held on 20.05.2026.
1.2 From the records available before us, it is observed that the applicant is engaged in the manufacture of boards using agricultural crop residues as the principal raw material. It has been submitted that the raw materials comprise bagasse, paddy straw and wheat straw procured from sugar mills and local farmers. It has further been stated that no wood, resin, synthetic adhesive or chemical binder is used in the manufacturing process. During the personal hearing, the applicant explained the manufacturing process, wherein the agricultural residues are cleaned, cooked, refined into pulp, converted into sheets and thereafter subjected to hot pressing, resulting in the manufacture of boards through natural bonding of fibres. The applicant has further placed on record purchase documents evidencing procurement of such agricultural residues.
1.3 The manufacturing process, as described in the application and supported by the photographs placed on record, broadly consists of receipt and storage of agricultural crop residues, followed by cleaning and preparation of the raw material, cooking/ steaming in digesters, mechanical refining through disc refiners, formation of pulp into sheets, drying, calendaring, cutting into standard sizes and storage of finished boards for commercial supply. The photographic record annexed with the application depicts various stages of the manufacturing process, including storage of agricultural residues, digesters, disc refiners, sheet formation, drying, calendaring, cutting and finished stock.
1.4 It is further borne out from the record that the finished product is marketed as “Straw Board”, “Agro Board” or “Eco. Board” and is supplied in sheet form in different thicknesses for use in bookbinding, file boards, stationery, packaging support layers and furniture backing applications.
1.5 The applicant has also relied upon an earlier Advance Ruling rendered by this Authority in the case of M/s Kailash Paper Board Mills, contending that the facts and manufacturing process are materially similar.
Jurisdiction under Section 97
2.1 The questions raised by the applicant are :-
1. Whether the boards manufactured by the applicant from agricultural crop residues such as bagasse, paddy straw, and wheat straw, using heat and pressure without any resin, synthetic adhesive, or chemical binder, are classifiable as particle boards or fibre boards for the purposes of GST.
2. Whether such boards are covered under Entry No. 292, sub-entry (h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025, which reads: “Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter.”
3. Whether the phrase “HSN 44 or any chapter” should be interpreted to grant the concessional GST rate of 5 percent to all particle or fibre boards made from agricultural crop residues, irrespective of their specific tariff heading, the decisive criterion being that they are wholly derived from agricultural crop residues and possess the essential character of fibre boards.
4. If, however, the product is not considered to fall within Entry 292 (h) of the above notification, under what HSN heading would the said boards appropriately fall, and what rate of GST would be applicable to them under the prevailing tariff and rate structure.
2.2 Before entering into the merits, it must be first satisfied that the application is maintainable under Section 97(2) of the CGST/HGST Act, 2017.
On a prima facie reading, all the above questions fall within the categories specified in Section 97(2):
I. Query No. 1 – falls under Section 97(2)(a), as it seeks determination of the classification of goods.
II. Query No. 2 – falls under Section 97(2)(b), since it seeks the applicability of a notification to the applicant’s product.
III. Query No. 3 – although framed as an interpretation of the words “HSN 44 or any chapter”, its real object is to determine whether the concessional entry in the notification applies to the applicant’s goods. Therefore, it is also covered by Section 97(2)(b).
IV. Query No. 4 – again falls under Section 97(2)(a) (classification) and, consequentially, determination of the applicable GST rate.
2.3 Accordingly, the application is prima facie maintainable under clauses (a) and (b) of Section 97(2), subject to the condition under Section 98 that the questions are not already pending or decided in the applicant’s own case. The applicant has specifically declared that no such proceedings are pending or decided.
Therefore the application is admitted to be decided on merits.
3. Issues for determination
3.1 On a consideration of the questions raised, the facts available on record and the submissions made by the applicant, the following issues arise for determination:
(i) Whether the product manufactured by the applicant answers the description of a “particle board” or a “fibre board” within the meaning of the Customs Tariff Act, 1975.
(ii) If so, under which heading of the First Schedule to the Customs Tariff Act, 1975, the impugned goods are appropriately classifiable.
(iii) Whether the goods so classified are covered by Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17.09.2025.
(iv) What is the true scope and effect of the expression “HSN 44 or any chapter” occurring in the said entry.
(v) Whether the earlier rulings rendered by this Authority in respect of similar products have any persuasive value in deciding the present application.
These issues are examined hereinafter.
4. Relevant Tariff Entry
4.1 The classification of goods under the GST regime is governed by the First Schedule to the Customs Tariff Act, 1975, read with the General Rules for the Interpretation of Import Tariff and the relevant Section Notes and Chapter Notes. The tariff entry relevant for the present controversy is Heading 4411 of Chapter 44, which reads as follows:
Heading 4411
“Fibre board of wood or other ligneous materials, whether or not bonded with resins or other organic substances.”
Notification No. 9/2025-Integrated Tax (Rate) dated 17.09.2025 prescribes the applicable rate of GST for specified goods.
The relevant entry is Entry No. 292(h), which reads as follows:
| Sr. No. | Description of Goods | |||
| 292(h) | Particle board or fibre board manufactured from agricultural crop residues – HSN 44 or any chapter
|
4.2 The scope of the above entry, particularly the expression “HSN 44 or any chapter”, also requires examination.
I) Chapter 44 is not confined to wood
GENERAL
This Chapter covers unmanufactured wood, semi-finished products of wood and, in general, articles of wood.
These products may be grouped broadly as follows:
(1) Wood in the rough (as felled, split, roughly squared, debarked, etc.) and fuel wood, wood waste and scrap, sawdust, wood in chips or particles; hoopwood, poles, piles, pickets, stakes, etc.; wood charcoal; wood wool and wood flour; railway or tramway sleepers (generally headings 44.01 to 44.06). However, the Chapter excludes wood, in chips, in shavings, crushed, ground or powdered, of a kind used primarily in perfumery, in pharmacy, or for insecticidal, fungicidal or similar purposes (heading 12.11) and wood, in chips, in shavings, ground or powdered, of a kind used primarily in dyeing or in tanning (heading 14.04).
(2) Sawn, chipped, sliced, peeled, planed, sanded, end-jointed, e.g., finger-jointed (i.e., jointed by a process whereby shorter pieces of wood are glued together end to end, with joints resembling interlaced fingers, in order to obtain a greater length of wood) and continuously shaped wood (headings 44.07 to 44.09).
(3) Particle board and similar board, fibreboard, laminated wood and densified wood (headings 44.10 to 44.13).
The General Explanatory Notes to Chapter 44 clarify that the Chapter covers, inter alia:
- particle board,
- fiberboard,
- laminated wood,
- densified wood.
More importantly, the Chapter Notes also state that Headings 44.10 to 44.21 apply to articles of particle board, fibreboard, laminated wood or densified wood as they apply to such articles of wood
ii). Heading 4411 is very significant
44.11 – Fibreboard of wood or other ligneous materials, whether or not bonded with resins or other organic substances.
– Medium density fibreboard (MDF):
4411.12 – Of a thickness not exceeding 5 mm
4411.13 – Of a thickness exceeding 5 mm but not exceeding 9 mm
4411.14 – Of a thickness exceeding 9 mm
– Other:
4411.92 – Of a density exceeding 0.8 g/cm³
4411.93 – Of a density exceeding 0.5 g/cm³ but not exceeding 0.8 g/cm³
4411.94 – Of a density not exceeding 0.5 g/cm³
Fibreboard is most often manufactured from wood chips which have been mechanically defibred (defibrated) or steam exploded or from other defibred ligne-cellulosic material (obtained e.g. from bagasse or bamboo). The fibres making up the board are recognisable under microscopic examination. They are bonded together in the board by felting and by their own adhesive properties, generally deriving from their lignin content. Additional resins or other organic bonding substances may be used to agglomerate the fibres. Impregnating or other agents may also be added during or after manufacture of the board to give an extra property, e.g. impermeability to water or resistance to rot, insect attack, fire or the spread of flame. Fibreboard may consist of a single sheet or of several sheets bonded together.
The Explanatory Notes expressly state that fibreboard may be manufactured from:
- wood chips, or
- other ligneo-cellulosic material, and then specifically give bagasse and bamboo as examples.
This is extremely important because the applicant’s principal raw material is bagasse along with other agricultural crop residues.
iii) Fibreboard need not contain resin
Another important observation is that the Explanatory Notes say:
” fibreboard consists of fibres bonded together by their natural felting properties or by additives”,
and further mention that additives may be introduced during or after manufacture to impart additional properties.
This means:
- resin is not an essential ingredient;
- absence of synthetic adhesive does not take the product outside Heading 4411
iv) Distinction between Heading 4410 and Heading 4411
The Explanatory Notes clearly distinguish:
Heading 4410
- Particle board is manufactured from wood chips, particles, agricultural residues, bagasse, etc., and is normally agglomerated by binders or added organic binders.
Heading 4411
- Fibreboard is manufactured from fibres, including fibres obtained from bagasse, and these fibres are bonded by felting or other processes.
- The HSN Explanatory Notes to Heading 4410 provide that particle board is generally manufactured from wood chips, particles or similar ligno-cellulosic materials, including agricultural residues and bagasse, which are normally agglomerated by means of an added organic binder. However the distinction between Heading 4410 and Heading 4411 does not depend upon the presence or absence of resin or other organic binders, since both headings expressly cover products whether or not bonded or agglomerated with such substances. The determining factor is the nature of the material constituting the board and the manufacturing process employed.
- On the other hand, the Explanatory Notes to Heading 4411 provide that fibreboard is manufactured from wood or other ligneo-cellulosic materials, including bagasse, after such materials are mechanically defibrated into fibres. The fibres are bonded together by their natural felting properties or with the aid of additives, and the heading specifically covers boards whether or not bonded with resins or other organic substances.
- In the present case, the manufacturing process placed on record shows that the agricultural crop residues are first subjected to digestion and thereafter passed through disc refiners where the material is converted into fibres. These fibres are then formed into sheets, pressed and dried to obtain the finished boards. The applicant has further stated that no resin or synthetic adhesive is used during the manufacturing process.
- The above manufacturing process indicates that the essential character of the product is derived from fibres obtained from ligno-cellulosic agricultural residues and not from wood particles or chips agglomerated with an added binder. The manufacturing process, therefore, corresponds more closely with the description of fibreboard under Heading 4411 than particle board under Heading 4410 as explained in the HSN Explanatory Notes.
- Accordingly, we are of the considered view that the impugned goods are appropriately classifiable under Heading 4411 of the First Schedule to the Customs Tariff Act, 1975.
Applicability of Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate)
5.1 Having held that the impugned goods are classifiable under Heading 4411 of the First Schedule to the Customs Tariff Act, the next issue for determination is whether they are covered under Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17.09.2025. Entry No. 292(h) reads as under:
“Particle board or fibre board manufactured from agricultural crop residues – HSN 44 or any chapter.”
5.2 A plain reading of the above entry shows that the benefit is available where the following conditions are satisfied:
(i) the goods are particle board or fibre board;
(ii) they are manufactured from agricultural crop residues; and
(iii) they are covered under “HSN 44 or any chapter.”
5.3 In the present case, it has already been held that the impugned goods are classifiable as fibreboard under Heading 4411. Further, the material on record establishes that the boards are manufactured from agricultural crop residues such as bagasse, paddy straw, wheat straw and mustard straw. Thus, the first two conditions prescribed in Entry No. 292(h) stand satisfied.The remaining issue relates to the interpretation of the expression “HSN 44 or any chapter.”
5.4 The expression is couched in broad terms and indicates the legislative intent that the benefit is not confined only to goods classifiable under Chapter 44. Had the intention been to restrict the benefit exclusively to Chapter 44, the words “or any chapter” would have been unnecessary. A settled principle of statutory interpretation is that every word used by the legislature must be given meaning and no part of a notification should ordinarily be treated as redundant or otiose.
5.5 Thus, the expression “HSN 44 or any chapter” expands the scope of the entry by making the description of the goods the governing criterion, rather than confining the benefit to a particular tariff chapter. Consequently, any goods answering the description of particle board or fibre board manufactured from agricultural crop residues would be eligible for the benefit, irrespective of the tariff chapter under which they may ultimately be classified.
5.6 The above interpretation is also consistent with the object underlying the introduction of Entry No. 292(h). The entry specifically grants a concessional rate to particle board or fibre board manufactured from agricultural crop residues, thereby encouraging the productive utilisation of agricultural residues such as bagasse and crop straw, which are otherwise liable to be disposed of by burning or other environmentally undesirable methods. The use of the brOad expression “HSN 44 or any chapter” further indicates that the legislative focus is on the nature of the goods and the source of the raw material, rather than restricting the benefit to a particular tariff chapter
5.7 Since the impugned goods are held to be fibreboard manufactured from agricultural crop residues and are classifiable under Heading 4411, they squarely satisfy the conditions prescribed in Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate).
6. Conclusion
6.1 In view of the foregoing discussion, we record the following findings:
(i) The boards manufactured by the applicant are produced from agricultural crop residues such as bagasse, paddy straw, wheat straw and mustard straw through a manufacturing process involving digestion, refining into fibres, sheet formation and hot pressing.
(ii) The manufacturing process establishes that the finished product is manufactured from defibrated ligno-cellulosic fibres and not by agglomeration of particles or chips. Consequently, the impugned goods answer the description of fibreboard under Heading 4411 of the First Schedule to the Customs Tariff Act, 1975.
(iii) Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate) grants concessional GST to “Particle board or fibre board manufactured from agricultural crop residues – HSN 44 or any chapter.” The applicant’s goods satisfy both essential conditions prescribed therein, namely, that they are fibreboard and are manufactured from agricultural crop residues.
(iv) The expression “HSN 44 or any chapter” indicates that the availability of the concessional rate is governed by the description of the goods and is not intended to be restricted to any particular tariff chapter. In the present case, however, the impugned goods are independently found to be classifiable under Heading 4411 of Chapter 44 itself.
Therefore, in light of above the ruling is as under:
| Sr. No |
Questions | Answers |
| 1. | Whether the boards manufactured by the applicant from agricultural crop residues such as bagasse, paddy straw, and wheat straw, using heat and pressure without any resin, synthetic adhesive, or chemical binder, are classifiable as particle boards or fibre boards for the purposes of GST. | Fibre boards |
| 2. | Whether such boards are covered under Entry No. 292, sub-entry (h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025, which reads: “Particle board or fibre board manufactured from agricultural crop residues-HSN 44 or any chapter. | Yes |
| 3. | Whether the phrase “HSN 44 or any chapter” should be interpreted to grant the concessional GST rate of 5 percent to all particle or fibre boards made from agricultural crop residues, irrespective of their specific tariff heading, the decisive criterion being that they are wholly derived from agricultural crop residues and possess the essential character of fibre boards. | 5% |
| 4. | If, however, the product is not considered to fall within Entry 292 (h) of the above notification, under what HSN heading would the said boards appropriately fall, and what rate of GST would be applicable to them under the prevailing tariff and rate structure. | NA |
